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Choose wording that accurately describes the cartoon
Make the label match the actual process. “AI-generated cartoon” is suitable when AI generated the work substantially. If an artist drew or composed the cartoon and AI played a narrower role, be specific: “AI-assisted” or “Background generated with AI.” Avoid wording that implies a person drew the whole image when that is not what happened, or that suggests full AI generation when AI only modified one element.
There is no universal required phrase, font, icon size, or placement for every cartoon in the EU guidance covered here. The practical test is whether the description is accurate and understandable to the intended audience.
Put the disclosure where viewers see it first
Place the words beside the cartoon or in the first visible caption line. For video, use an on-screen label or an opening caption if that is how viewers first encounter it. Keep it legible without covering faces, lettering, or an important visual detail. Do not rely only on metadata, a hidden provenance mark, or a caption that appears only after viewers select “more.”
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The European Commission’s practical guidance says a disclosure must be clear and distinguishable, understandable, and perceivable without special tools or a dedicated action. A machine-readable mark can serve a technical purpose, but by itself it does not satisfy a viewer-facing disclosure duty where one applies.
What the EU AI Act requires—and when
The EU AI Act distinguishes between providers of generative AI systems and the people or organizations that deploy them. Providers must ensure covered outputs are marked in a machine-readable format and detectable as artificially generated or manipulated, subject to the Act’s qualifications. Deployers have a disclosure duty for image, audio, or video content that constitutes a deepfake. The Commission says Article 50 applies from 2 August 2026. European Commission guidance on AI-generated content
The Act’s deepfake category concerns content that resembles existing people, objects, places, entities, or events and falsely appears authentic or truthful. Whether a cartoon falls within that category depends on its content and context, including whether viewers could reasonably take it as authentic. An obviously fictional cartoon will not necessarily meet that definition.
For evidently artistic, creative, satirical, fictional, or analogous work, Article 50(4) says any required disclosure should be made in an appropriate manner that does not hamper the work’s display or enjoyment. A discreet but findable caption can fit that standard better than a warning that obscures the art. The Act does not prescribe a single label treatment for every cartoon. EU AI Act, Article 50
Do not confuse the provider’s mark with the audience disclosure
The provider’s machine-readable marking obligation and a deployer’s visible disclosure are separate duties. Retain machine-readable provenance when the tool provides it, but do not treat hidden technical metadata as a substitute for a clear notice to viewers where disclosure is required.
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Account for the transition dates
The Commission describes a limited grace period until 2 December 2026 for providers’ marking and detection duties for AI systems placed on the market before 2 August 2026. It does not describe that grace period as delaying deployer disclosure duties. Content created before 2 August 2026 does not need retroactive labeling, though the Commission encourages labeling where possible. European Commission guidance on AI-generated content
Use an optional EU icon as support, not a substitute
The European Commission offers optional icons for AI-generated-content disclosure. Its guidance distinguishes fully AI-generated content from content modified with AI and says the basic icon performed better across the measures described when accompanied by text. The page provides no numeric effect size, so there is no supported percentage to quote. EU icons for labelling AI-generated content
If you use an icon, pair it with a short phrase such as “AI-generated cartoon” or, when accurate, “AI-modified.” Choose the icon that reflects the extent of AI involvement. Icons are optional; using one does not by itself establish compliance, and the deployer remains responsible for any required disclosure.
Check the label before publishing
- Accuracy: Does it distinguish full generation from limited AI assistance or modification?
- First-exposure visibility: Can viewers see it beside the cartoon or in the first caption line?
- Readability: Is the wording clear and legible without an extra click or special tool?
- Fit with the medium: Does the label work for the image, post, or video format?
- Respect for the artwork: Is it visible without blocking a key detail or spoiling the work’s display and enjoyment?
Platform controls may complement a visible label, but platform rules are separate from legal duties and can change. Check the service’s current upload settings and rules for the account and format you use.
Scope of this guidance
This legal summary concerns EU-level sources current to 7 October 2026; it is not a statement of law for every country or platform. The EU rules described here do not establish the requirements that apply in other jurisdictions. Check the applicable local rules and the platform’s current guidance before publishing.
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